2023 (12) TMI 278

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..... Sgri Abhay Agrawal, Advocate ORDER PER SATBEER SINGH GODARA, J.M. : This Revenue's appeal for assessment year 2013-14, arises against the CIT(A)-3, Nagpur's Order in Appeal No. CIT(A)-3/6/2018-19, dated 29.04.2019, involving proceedings u/s. 154 r.w.s. 143(3) of the Income Tax Act, 1961 (in short "the Act"). Heard both the parties. Case file perused. 2. The Revenue raises the following s .....

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..... O was therefore justified in disallowing the prior period expenditure amounting to Rs. 16,30,873/-. 3. Any other ground which may be taken with the permission of the Hon'ble Tribunal." 3. It next emerges with the able assistance coming from both the parties that there is hardly much a need for us to delve deeper in the relevant factual matrix once it has come on record that we are dealing with .....

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..... at pages 3 to 6 of the assessee's paper book. That being the case, we quote hon'ble apex court's landmark decision in T.S. Balram, ITO vs. Volkart Brothers [1971] 82 ITR 50 (SC) that purpose of sec. 154 rectification is only to deal with apparent mistakes on record than those involving detailed roving enquiries and confirm the CIT(A)'s action reversing the Assessing Officer's impugned action t .....

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